Question:If the bank does not escrow for taxes or homeowner’s insurance, do we still have to escrow for flood insurance under the rule? If yes, does the bank then have to escrow for taxes and insurance because it’s required to escrow for flood insurance?

Answer: If the bank is required to escrow for flood insurance under the new rules, they are required to do so even if the bank doesn’t or doesn’t have to escrow for taxes or insurance. Note that the bank can always require escrow even when it’s not required.